MyCognition Limited is a private limited company incorporated in England and Wales under registered company number 07875247 with its registered office at Camburgh House, 27 New Dover Road, Canterbury, Kent CT1 3DN and is a ‘controller’ under the General Data Protection Regulation and the Data Protection Act 2018

Whose data do we hold?

We may hold data about the following people:

Employees

Customers and clients

Suppliers and service providers

Advisers, consultants and other professional experts

Complainants and enquirers

What data will we collect?

We will only collect information from you that is relevant to the matter that we are dealing with. In particular we may collect the following information from you which is defined as ‘personal data’:

Personal details

Family, lifestyle and social circumstances

Cognitive profile

Financial details

Business activities of the person whose details we are processing

Special Categories

We may also collect information that is referred to as being in a ‘special category’. This could include:

Physical or mental health details

Racial or ethnic origin

Religious beliefs or other beliefs of a similar nature

Criminal convictions

Sexual orientation

Basis for processing

The basis on which we process your personal data is one or more of the following:

It is necessary for the performance of our contract with you

It is necessary for us to comply with a legal obligation

It is in our legitimate interests to do so

You have given us your consent (this can be withdrawn at any time by advising our data protection officer) either directly or through your trial manager

How will we use your data?

We may use your information for the following purposes:

Delivery and provision of our cognitive fitness programmes

Promotion of our goods and services

Provision of education and training to customers and clients

Maintaining accounts and records

Supporting and managing staff

To continually enhance the statistical accuracy of our measures and efficacy of our cognitive intervention

Who will we share your Information with?

Under our Code of Conduct there are very strict rules about who we can share your information with and this will normally be limited to other people who will assist with the delivery of your cognitive fitness and training programme. This may include:

Healthcare professionals

Training partners

Teachers (in the case of the use of MyCognition in a school setting)

Clinical trial managers

In each case, the data will only be shared once you or your legal representative (in the case of minors) has provided explicit consent to do so.

Where you authorise us we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our invoices.

How long will we keep your information for?

We will normally keep your information throughout the period of time that we do work for you and afterwards for a period of six years as we are required to do by law and also by the regulations that apply to us.

In some cases (for example where we have prepared a will for you) we may retain your information for a longer period and we will advise you of this at the time

More information is set out in our data retention policy which is available on request from the data protection officer

Transfers to third countries

We may from time to time transfer your personal data to a country outside of the EEA.

Normally this will be necessary for the performance of your contract with us

Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times

Security arrangements

We shall ensure that all the information that you provide to us is kept secure using appropriate technical and organisational measures.

In the event of a personal data breach we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate.

More information is available from the data protection officer.

What rights do you have?

You have the following rights under the GDPR:

Right to be informed

Right of access

Right to rectification

Right to erasure

Right to restriction of processing

Right to data portability

Right to object

Rights concerning automated decision-making and profiling

Right of access

You have a right to see the information we hold about you

To access this, you need to provide a request in writing to our data protection officer, together with proof of identity

We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex

Full details are available in our data subject access policy which is available on request from the data protection officer

Right to erasure

You have a right to ask us to erase your personal data in certain cases (details may be found in Article 17 of the GDPR).

We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by low or regulation, or that is required to exercise or defend /ego/ claims.